#Transfer Pricing
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1,377 articlesIncome Tax
Income Tax
CUP method can be applied by a comparing a pricing formulae instead of pricing quantification in amount
Income Tax
Income Tax
Unilateral action on the part of one party with absence of mutual agreement cannot result into an international transaction
Income Tax
Income Tax
Revenue must show existence of agreement/ understanding with foreign entity before any TP adjustment for AMP expenditure
Income Tax
Income Tax
If business of comparable company & assessee remains unchanged from last year, the company can’t be held incomparable in current year
Income Tax
Income Tax
Mere incidental benefits to foreign AE from AMP expenses cannot be a basis for existence of an international transaction
Income Tax
Income Tax
DRP cannot absolve from its duty without going into merits of contention of assessee while deciding comparability
Income Tax
Income Tax
TP: Companies in production & sale of software products cannot be compared with those in development of software on contract basis
Income Tax
Income Tax
Transfer Pricing: Revenue can’t adjust operating costs in allowing capacity adjustment
Income Tax
Income Tax
Foreign exchange gain/loss arising out of revenue transactions is required to be considered as an item of operating revenue/cost
Income Tax
Income Tax
Transfer Pricing Applicability to Dairy Co-operative societies
Income Tax
Income Tax
TPO can reject transfer pricing study report based on multiple year data and use only current year data
Income Tax
Income Tax
Revenue cannot file appeal against voluntarily decision of AO/TPO
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Income Tax
Transfer Pricing: Only functionally comparable companies can be compared for calculating ALP
Income Tax
Income Tax
